The CFC taxation is intended to prevent profits from being removed from German taxation by establishing companies in low-tax countries. It affects foreign intermediate companies controlled by individuals residing in Germany and generating passive income subject to low taxation (< 25%). Even without a place of management in Germany, the income of such companies can be taxed in Germany under §§ 7 ff. of the Foreign Tax Act (AStG). This applies to both direct and indirect holdings.

Our Services

We offer comprehensive consulting services in the area of allocation taxation, covering the following aspects:

• We analyze your international corporate structure and check whether the allocation taxation applies, and assist you in the tax-optimal planning of your foreign activities.

• We calculate the amount of the allocation tax and look for ways to minimize the tax burden, for example, by utilizing exceptions or through structural adjustments.

• We support you in preparing the necessary documentation and fulfilling the legal reporting obligations to minimize tax risks.

• In disputes with the tax authorities, we represent your interests and defend your position against the tax authorities.

Why Us?

Through our many years of experience and specialization in international tax law and allocation taxation, we provide you with sound and practice-oriented solutions. Our expertise helps you minimize tax risks and design your corporate structure efficiently and legally secure.

Contact

Do you have questions about allocation taxation or need assistance with the tax optimization of your international activities? Contact us for a non-binding consultation. Use our contact form to reach out to our experts and receive tailored solutions for your tax concerns.